Tendering of Legal Documents before Courts: Procedure, Admissibility, Proof, Objections and Evidentiary Value
By

-- Geetu Raheja, Advocate, Delhi High Court --

INTRODUCTION

Tendering of legal documents is an important stage in judicial proceedings. A document may be in possession of a party, but it does not automatically become evidence merely because it is filed with the plaint, written statement, petition, reply or affidavit. For a document to be considered by the court, it must be properly tendered, proved and exhibited in accordance with law. The process of tendering documents ensures that only reliable, relevant and legally admissible material forms part of the judicial record.

MEANING OF TENDERING OF DOCUMENTS

Tendering of documents means the formal act of producing a document before the court during evidence, with a request that it be taken on record and marked as an exhibit. It is usually done through a witness who identifies the document, proves its execution, source, custody or contents, and connects it with the facts in issue.

For example, a sale deed, agreement, receipt, notice, postal record, medical report, bank statement, photograph, CCTV footage, WhatsApp chat, email or certificate must be tendered through proper evidence before the court can rely upon it.

DIFFERENCE BETWEEN FILING AND TENDERING

There is a clear distinction between filing a document and tendering a document.

Thus, a document may be on the court file but still have no evidentiary value unless it is duly proved according to law.

RELEVANCE AND ADMISSIBILITY

Before a document is tendered, the court considers two basic questions:

1.    Whether the document is relevant to the dispute.

2.    Whether the document is legally admissible.

A document may be relevant but still inadmissible if it is unstamped, insufficiently stamped, unregistered where registration is compulsory, privileged, forged, or not proved in the manner required by law.

In India, the rules relating to proof of documents are now governed by the Bharatiya Sakshya Adhiniyam, 2023, which has replaced the Indian Evidence Act, 1872. The official Act recognises proof of electronic records and provides that contents of electronic records may be proved in accordance with Section 63.

PRIMARY AND SECONDARY EVIDENCE

Ordinarily, a document should be proved by producing the original document, which is known as primary evidence. Where the original is unavailable for legally acceptable reasons, a party may seek to prove the document by secondary evidence, such as a certified copy, photocopy, counterpart, duplicate or oral account of the contents, subject to fulfilment of legal conditions.

The party relying on secondary evidence should explain why the original document cannot be produced. Courts generally require a proper foundation before allowing secondary evidence.

PROCEDURE FOR TENDERING DOCUMENTS

The usual procedure for tendering legal documents is as follows:

1.    The party files a list of documents.

2.    The witness enters the witness box.

3.    The document is shown to the witness.

4.    The witness identifies the document.

5.    The witness explains its execution, source, custody or relevance.

6.    The opposite party is given an opportunity to object.

7.    The court decides whether the document should be marked.

8.    If accepted, the document is marked as an exhibit.

In civil cases, documents are generally exhibited as Ex. PW-1/1, Ex. PW-1/2, etc., for the plaintiff’s witnesses and Ex. DW-1/1, Ex. DW-1/2, etc., for the defendant’s witnesses. In criminal cases, documents may be exhibited through prosecution or defence witnesses, such as Ex. P-1, Ex. PW-1/A, or similar markings depending on court practice.

OBJECTIONS AT THE TIME OF TENDERING

The opposite party has a right to raise objections when a document is tendered. Common objections include:

1.    Document is irrelevant.

2.    Document is forged or fabricated.

3.    Original has not been produced.

4.    Photocopy is inadmissible.

5.    Document is insufficiently stamped.

6.    Document requires registration.

7.    Author or signatory has not been examined.

8.    Electronic record is not supported by the required certificate.

9.    Document is hearsay or not proved by a competent witness. 

Objections should normally be raised at the time when the document is tendered. If a party remains silent, certain objections relating to mode of proof may be treated as waived, although objections relating to inherent admissibility may still be considered by the court.

TENDERING OF ELECTRONIC RECORDS

In modern litigation, electronic documents are frequently tendered before courts. These include emails, WhatsApp chats, call detail records, CCTV footage, screenshots, audio-video recordings, computer printouts, digital photographs, server logs and online records.

Under Section 63 of the Bharatiya Sakshya Adhiniyam, electronic records may be admissible when the prescribed conditions are satisfied. The provision requires a certificate identifying the electronic record, describing how it was produced, giving particulars of the device involved, and addressing the conditions relating to regular use and proper operation of the computer or communication device.

Therefore, while tendering electronic evidence, the party should normally produce:

1.    the electronic record,

2.    printout or copy, where applicable,

3.    certificate under Section 63,

4.    details of device/source,

5.    witness who can identify and support the record. 

MARKING FOR IDENTIFICATION AND MARKING AS EXHIBIT

Sometimes, the court may not immediately exhibit a document due to objection or incomplete proof. In such cases, the document may be marked for identification, such as Mark A or Mark X. This does not mean that the document has been proved. It only shows that the document was produced before the court.

A document marked for identification has weaker evidentiary value than a duly exhibited document. The party must still prove it properly before relying upon it.

IMPORTANCE OF TENDERING DOCUMENTS PROPERLY

Proper tendering of documents is important because it affects the final outcome of the case. Even a strong document may become useless if it is not proved correctly. Courts decide cases on legally admissible evidence, not merely on allegations or papers placed on the file.

A properly tendered document helps in:

1.    proving the facts in issue,

2.    corroborating oral testimony,

3.    disproving the opponent’s case,

4.    establishing legal rights,

5.    supporting damages or compensation,

6.    proving service of notices,

7.    proving transactions, payments, possession or ownership. 

PRECAUTIONS WHILE TENDERING DOCUMENTS

A lawyer or litigant should keep the following precautions in mind:

1.    Always keep originals ready.

2.    File complete and legible copies.

3.    Check stamp duty and registration requirements.

4.    Prepare proper affidavit of evidence.

5.    Ensure that the correct witness proves the document.

6.    For electronic records, prepare the required certificate.

7.    Raise objections at the correct stage.

8.    Do not rely only on photocopies without legal foundation.

9.    Make sure exhibit numbers are correctly recorded.

10. Link each document with the pleadings and issues.

CONCLUSION

Tendering of legal documents is not a mere formality. It is a vital part of the law of evidence. A document becomes useful in litigation only when it is relevant, admissible and duly proved. Proper tendering gives authenticity and evidentiary value to documents, while defective tendering may result in exclusion or limited reliance. Therefore, every advocate and litigant must carefully follow the procedure for producing, proving and exhibiting documents before the court.


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